Petitioner Estopped Because References Reasonably Could Have Been Raised in Its Earlier IPR By Hala S. Mourad on September 6, 2016 Email this postTweet this postLike this postShare this post on LinkedIn In Praxair Distribution, Inc. v. INO Therapeutics, LLC., IPR2016-00781, Paper 10 (Aug. 25, 2016), the Board denied Praxair’s inter partes review petition based on both estoppel under 35 U.S.C. § 315(e)(1) and the PTAB’s discretion under § 325(d). Read more